Document background
An Intragroup Loan Agreement is essential for documenting financial arrangements between entities within the same corporate group under Dutch law. This document is typically used when one group entity provides financing to another, whether for operational needs, expansion, acquisition financing, or general corporate purposes. The agreement must comply with Dutch civil law requirements and financial regulations, while incorporating transfer pricing considerations to ensure arm's length terms. It includes comprehensive provisions covering loan amount, interest rates, repayment terms, security (if any), and events of default. The document is particularly important for maintaining proper corporate governance, ensuring tax compliance, and creating a clear audit trail for both internal and external stakeholders. Given the Dutch legal framework, special attention is paid to thin capitalization rules, interest deductibility limitations, and other relevant tax provisions.
